Embargo (we) are committed to protecting and respecting your privacy.
1. Scope of Policy
- The Embargo mobile application software (App)), which is hosted on third party mobile application download sites (App Site(s)), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the Data Protection Act 1998, the data controller is Embargo Lifestyle Limited of 53D Moscow Road, London, W2 4JS.
2. Information we may collect from you
We may collect and process the following data about you:
- Information you give us (Submitted information): You may give us information about you by filling in forms on the App, the Site or the App Site, or by corresponding with us (for example, by e-mail or chat). This includes information you provide when you register to use the App Site, download or register the App, subscribe to the Service, share data via the App's social media or communication functions, enter a competition, promotion or survey and when you report a problem with the App, the Service, or the Site. The information you give us may include your name, address, e-mail address and phone number, the Device's phone number, birthday, place of residence, username, password and other registration information (including log-in details and profile information from third party social media sites), financial and credit card information, personal description and photograph.
- Information we may collect about you and your device. Each time you visit the Site or use our App we may automatically collect the following information:
- technical information, including the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, (Device Information);
- details of your use of our App or the Site including, but not limited to, time spent in our partner business venues, your activity on the App and use made of our partner business offers via the App, traffic data, location data, weblogs and other communication data and the resources that you access (Log Information).
- Location information. Where activated and you have consented to this on your mobile device, we will use beacon location and/or GPS location technology to determine your current location and when you have entered any of our partner business venues. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. Please note that you are likely to lose some or all of the functionality of the App if you do not permit the App to use location-tracking technology.
- Information we receive from other sources (Third Party Information). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
- Unique application numbers: when you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
In order to improve the Sites, we may use small files commonly known as “cookies”. A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone (referred to in this policy as a ‘device’) from the Sites and is stored on your device’s hard drive.
A cookie records on your device information relating to your internet activity (such as whether you have visited our website before). The cookies we use on the Sites won’t collect personally identifiable information about you and we won’t disclose information stored in cookies that we place on your device to third parties.
4. Uses made of the information
We use information held about you in the following ways:
- Submitted Information: to personalise our Service to you and ensure you are able to receive the full benefit of the App and its features.
- Device information: to optimise the App to the screen of your device and to make sure the App and the Service operates effectively on your device. To ensure that we can automate certain of the features of the App and avoid the need for multiple log-in procedures when interfacing with third parties (for example when automatically logging you in to our business partner’s wifi services’).
- Log information: Among other things to ensure that we can accurately assess the time you spend in our business partner venues and ensure that you accrue the correct number of visits during your stay there as well as to monitor your use of visits and maintain an accurate statement of your account.
- Location information: To ensure the App operates effectively when you visit one of our partner business venues, to inform our partner business venues that you have entered their premises and to enable us and our partner business venues to provide you with App-related notifications when you are in the vicinity of a venue.
5. Disclosure of Information
We may disclose some or all of the data we collect from you when you download or use the App to the following third parties:
Category of data
Submitted Information, Log information and Location Information
Our partner business venues. The App and the Service we provide through the App relies on us being able to disclose certain elements of this data to our partner business venues so that they can interact with you and provide you with App relates offers and services.
Other business partners. We may share certain data with organisations who are our business partners and we or they may contact you (unless you have asked us or them not to do so) by email about promotions and special offers that may be of interest to you. If you prefer not to receive any direct marketing communications from us, you can opt out at any time. See further 'Your rights', below.
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Embargo Lifestyle Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
- In order to:
- protect the rights, property or safety of Embargo Lifestyle Limited our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6. Where we store your Personal Data
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk.
7. Your rights
You may be aware that a new European Union law, called the General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. As available and except as limited under applicable law, the rights afforded to individuals are:
- Right of Access - the right to be informed of and request access to the personal data we process about you;
- Right to Rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;
- Right to Erasure - the right to request that we delete your personal data;
- Right to Restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data;
- Right to Object
- the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
- the right to object to your personal data being processed for direct marketing purposes;
- Right to Data Portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
You can exercise all rights at any time by contacting us at firstname.lastname@example.org.
8. Third party sites
Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.